Reassessment for Change of opinion in Absence of new material not justified

Kalpana Chimanlal Shah Vs ITO (Gujarat High Court)

The entire issue was examined by AO in the original scrutiny assessment. Any attempt on his part now to reexamine the issue would amount to change of opinion. Further, neither from the reasons nor from any other material on record, it could be gathered that there was any failure on the part of assessee to disclose truly and fully all material facts. Hence, reopening of assessment was wholly impermissible in law.

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